Privacy Notice for Shareholders, Debenture Holders, and Directors
Long Son Petrochemicals Co., Ltd respects the rights to privacy of our Shareholders including individuals
acting on behalf of our Shareholders such as authorized representatives in members’ council. To ensure that your personal data is protected, we have
created this Privacy Notice to provide information on our processing of your
personal data, in electronic and other formats, in accordance with the Vietnam
Personal Data Protection Laws.
1.
Definitions
1.1. “We” means Long Son Petrochemicals Co., Ltd
1.2. “You” mean shareholders,
members’ council and related persons which include but are
not limited to attorneys, nominees, agents, associates, spouses, parents,
siblings, children, spouses of children, and connected persons under applicable
law;
1.3. “Processing” means any
acts impacting personal data, including but not limited to collecting,
recording, analyzing, confirming, storing, editing, publicizing, disclosing,
combining, accessing to, retrieving, recovering, encrypting, decrypting,
copying, sharing, transmitting, providing, transferring, deleting, destroying
personal data.
1.4. “Vietnam Personal
Data Protection Laws” mean applicable Vietnamese laws on personal data
protection, including any amendments, supplements or replacement from time to
time.
1.5. “SCG Group” means the
Siam Cement Public Company Limited, including its subsidiaries, associates and
affiliates.
2.
Purposes of the processing
2.1. We process your
personal data for the following purposes:
(1)
to comply with legal obligations related to corporate matters,
financial markets, and other applicable international and local laws. This
includes incorporation, capital changes, business restructuring, and
registration updates. Specifically, we process your personal data to:
·
Arrange and organize shareholders' meetings or members’ council meetings.
·
Select and nominate directors and arrange and organize board
meetings.
·
Arrange and organize board meetings.
·
Manage the rights and duties of shareholders, members’ council.
·
Pay dividends and interest.
·
Produce, submit, and publicize accounting and legal reports.
·
Comply with laws governing limited companies
·
Adhere to competent authorities' rules, regulations, and
orders.
(2) to perform our obligations with you or to take steps at your
request before entering into an agreement. This includes paying remuneration, and
enabling your participation in activities.
(3) to manage our companies, accommodate you, and organize
meetings, including producing, recording, and disclosing reports, as well as
recording video or audio during meetings.
(4)
to disclose and publicize documents and information related to
meetings or events.
(5)
to organize events and send you news or offers for your
benefit.
(6)
to restructure, sell, or transfer our business and assets when
necessary.
(7)
to establish, exercise, or defend legal claims, whether they
pertain to you or us.
(8) to ensure your security, which may involve implementing
security measures (e.g., controlling access to premises), preventing and
managing epidemics, and verifying and authenticating identities for website or
application access.
(9) to protect vital interests, whether yours or someone else's.
This includes, for example, making contact in case of an emergency or
controlling and preventing the spread of diseases.
(10)
to perform tasks in the public interest or in the exercise of
official authority vested in us.
Please note that the
above list is not exhaustive and may be subject to updates as necessary.
2.2. If we process your
personal data for purposes that require consent, we will inform you of these
specific purposes at the time of obtaining your consent. Further details
regarding your consent and its implications are provided in the subsequent
sections of this Privacy Notice.
3.
Personal data we collect
We collect personal data directly from you and indirectly
from other reliable sources such as government agencies, companies in the SCG Group, business partners,
and individuals who can legitimately disclose your personal data.
The details of the data collection are as follows:
(1)
Names, surnames
(2)
Addresses
(3)
Telephone numbers
(4)
Email addresses
(5)
Nationalities
(6)
Dates of birth
(7)
Places of birth
(8)
Tax ID
(9)
Identification numbers
(10)
Passport numbers
(11)
Photographs
(12)
Audio record, videos
(13)
Bank accounts
(14)
Signatures
3.2. Additional Data
Collection: If we need to collect additional personal data, we will notify you and
process the data in compliance with Vietnam Personal Data Protection Laws.
3.3. Sensitive Personal
Data:
Where necessary, we will process your sensitive personal data in accordance
with Vietnamese Personal Data Protection Laws. We will ensure that we will try
our best to provide adequate security measures to protect your sensitive
personal data. We may need to collect and process sensitive personal data,
including:
(1) We may collect and
process your facial recognition or fingerprint data to verify your identity.
(2) We might have to collect
general health data given by you (e.g. food allergy, drug allergy, vaccination)
to organize events, meetings, and receptions; to accommodate you; and to comply
with legal and regulatory requirements (e.g. criminal offence data).
(3) In some occasions, we might receive your sensitive personal
data although we have no intention process the data. For example, we might
receive data concerning your religious beliefs when we collect copies of your
identification cards, which we will take appropriate measures to prevent
collection and processing of such unnecessary data or ask you to redact the
data before sending it to us.
(4) Sensitive personal data under our processing may also include
financial information and location data.
3.4. Third-Party Data
Disclosure: If you disclose personal data of other persons to us, you must be able
to disclose such data and comply with applicable laws, which includes informing
the data subjects of this Privacy Notice and other relevant documents before or
when you disclose the data to us.
4.
Cookies
4.1. We use cookies and
similar technology to collect personal data as specified in our Cookies
Notice.
5.
Consent, withdrawal, and consequences
5.1. If we rely on your
consent to process personal data, you are entitled to withdraw your given
consent at any time but such withdrawal will not affect the validity of the
processing made prior to the withdrawal.
5.2. Your withdrawal of
consent or refusal to provide certain information may result in us being unable
to fulfill some or all of the objectives stated in this Privacy Notice.
5.3. You can withdraw your
given consent by following instructions available in the channels that obtain
consent from you (e.g. changing settings in your user accounts) or by submitting your request to relevant channels in Section 10.
5.4. If you are
quasi-incompetent person, or incapacitated persons and you wish to give consent
to us; you must obtain authorization from your lawful representatives,
guardians or custodians (depending on the specific
context of each case) before giving consent to us.
5.5. If you give us
consent on behalf of other persons, you must have authority to legally give the
consent on behalf of the data subjects at the time when it is given to us.
6.
Retention Period
6.1. We will retain your
personal data for the period necessary to meet the objectives unless the law
requires longer retention periods. In the event that such period is unclear, we
will retain the data for a customary expected period in accordance with retention
standards.
6.2. We have established
an auditing system to delete or destroy your personal data when the retention
period expires or when it becomes irrelevant or unnecessary for the purposes of
collecting that personal data.
6.3. If your personal data
is processed based on consent, we will stop the processing when you have
withdrawn the consent. However, we may keep your personal data to record your
withdrawn so we can respond to your request in the future.
7.
Disclosure of Your Personal Data
7.1. We disclose and share
your personal data with:
(2) Individuals and entities other than the companies in the SCG
Group for the purpose of collecting and processing personal data as described
in this Privacy Notice such as our dealers, transport and logistics service
providers, postal service providers, data processing service providers,
marketing service providers (who might send messages to you to promote our
products and services), contractors (who might perform tasks on our behalf),
financial service providers (such as banks, payment companies, electronic
payment service providers, credit providers), IT service providers (such as
providers of cloud services, blockchain systems, data analytics, SMS, or
emails), IT developers, programmers, auditors, consultants, advisors,
government agencies (e.g. the tax authorities), insurers, legal advisors, third parties (in Vietnam or anywhere else)
that are related to subpoenas, court orders, or other legal processes or
requirements under the laws or regulations of Vietnam or laws and regulations
of other jurisdictions that apply to us, our affiliates, or financial
institutions to manage risks and to help detect and prevent illegal acts and
fraud that may occur and other violations to our policies and agreements, and
other persons to the extent necessary to enable us to conduct business, provide
products and services, and meet the purposes for the collection and processing
of personal data as described in this Privacy Notice.
7.2. Recipients of your
personal data in clause 7.1 might have their own separate privacy notice,
please read their respective privacy notice to see details of how they process
your personal.
7.3. When we restructure
our business, sell or transfer assets, acquire businesses or are acquired by
other businesses, or merge with other businesses; we might have to disclose
your personal data to our counterparties and their advisors. However, we will
use our best effort to safeguard your data and require our relevant
counterparties and their advisors to comply with applicable personal data
protection laws and this Privacy Notice.
7.4. We will require
persons receiving your personal data to take appropriate measures to protect
your personal data, process the data properly and only as necessary, and
prevent unauthorized use or disclosure of your personal data.
8.
International transfer of your personal data
8.1. We may send or
transfer your personal data to companies in the SCG
Group or other persons located outside Vietnam if it is necessary in
order for us to perform the purposes of processing as set out under Section 2
of this Privacy Notice.
8.2. We may
store your personal data on computer servers or clouds located outside Vietnam
and use software or applications of service providers located outside Vietnam
to process your personal data. However, we will not allow unrelated parties to
access to your personal data and will require the service providers to have
appropriate security measures to protect your data.
8.3. In the event that
your personal data is transferred to a foreign country, we will comply with
applicable personal data protection laws and take appropriate measures to
ensure that your personal data is protected and you can exercise your rights in
accordance with the laws. Moreover, we will require those who receive the data
to have appropriate protection measures for your personal data, to process such
personal data only as necessary, and to take steps to prevent unauthorized use
or disclosure of your personal data.
9.
Security Measures
9.1. We have implemented
appropriate technical and administrative standards to protect your personal
data from loss, misuse, and unauthorized access use, disclose, or destruction.
We use technology and security procedures such as encryption and access restriction
to ensure that only authorized people shall have access to your personal data,
and that they are trained about the importance of protecting personal data.
9.2. We provide
appropriate security measures including administrative, technical, and physical
safeguards (such as access control and user access management) to prevent
unlawful loss, access, use, change, disclosure of personal data from those who
do not have rights or duties related to that personal data. We will review the
above-mentioned measures when necessary or when the technology changes to
ensure effective security.
9.3. If we process your
sensitive personal data, we will use our best endeavor to impose
appropriate security measures to protect the data.
10. Your rights and
obligations as data subjects
10.1. Your rights under the
Vietnam Personal Data Protection Laws can be summarized as follows:
(1)
Right to be aware of the processing of your personal data;
(2)
Right to give and withdraw consent you given to us;
(3)
Right to request to view and correct your personal data;
(4) Right to oppose our use or disclosure of personal data about
you for marketing and advertising purposes;
(5) Right to request us to delete or destroy or make your personal
data non-personally identifiable (anonymous) information;
(6)
Right to request us to restrict the processing of your
personal data;
(7)
Right to request us to provide your personal data; and
(8) Right to file complaints, denunciation, or lawsuit to the
authority, to claim damages, and to exercise self-defense mechanisms in the
event that we, our data processors, our employees, or our contractors violate
or do not comply with personal data protection laws.
10.2. We will consider your request, notify the result of the
consideration, and execute it (if appropriate) within a reasonable timeframe
from the date we receive the request. Your rights mentioned above will be in
accordance with the Vietnam Personal Data Protection Laws.
10.3. You may exercise your
rights under the law by submitting your request to compliance@lsp.com , or via our website and/or announced application.
10.4. Besides rights, you as the
data subject bear certain obligations pursuant to Vietnam Personal Data Protection
Laws, including but not limited to the obligation to provide complete
and accurate personal data when consenting to the processing of personal data.
11.
Information about data controller and Data Protection
Officer
11.1. Data Controllers: The data controller of this Privacy Notice
is Long Son Petrochemicals Co., Ltd
11.2. Business Address: The business addresses of the data
controller is Hamlet 2, Long Son commune, Ho Chi
Minh City.
11.3. Contact Information: You can contact the data controller
or inquire about this Privacy Notice by emailing compliance@lsp.com.
In the event that this Privacy Notice is amended, we will announce a new privacy notice on this website or other channels of notification, which you should periodically review the privacy notice. The new privacy notice will be effective immediately on the date of announcement.